2018), you need to quickly—if not already—have
processes in place to begin collecting the additional
data on these loan applications. However, there are
still many unanswered questions that make this data
collection difficult. In April 2017, the CFPB released
proposed changes to the rule to increase clarity
within the currently published rule and commentary.
This publication has been useful to allow us to better
understand the intent of some of the data points as
we outline and write out data collection procedures;
however, until this is finalized and the 2018 HMDA
error codes are released, it makes it difficult to write
procedure on some of the nuances of the HMDA
data that we need to be collecting today for our
2018 final action loans.

Speaking of things that may be difficult, have
you obtained your Legal Entity Identifier (LEI) yet?
If not, you may want to make this a priority quickly,
as you may be surprised at the challenges you may
face completing the application.

As we have been working to implement the
necessary policies, data collection changes, and
trainings, we have identified as well as received
input from other compliance officers regarding some
technological challenges that you may also need to
consider as you are finalizing your 2018 HMDA plan.

The first and biggest of these challenges maybe your data collection systems. Has your LOSprovider already launched their HMDA solution?Do you have multiple LOS’s for various channels orproducts (HELOC, Reverse Mortgages, Brokered,and Correspondent)? If you are working in multiplesystems, or have multiple lines of business, you getto do HMDA implementation for each of these; doyou have the time and staffing available to test eachof these? What is your back-up plan if the systemis not ready to launch when you are? Is your loannumbering convention different enough that youwon’t produce the same ULI on different files indifferent systems ever? Do the online applicationtools that integrate into your LOS have a plan tobe ready to launch into the 2018 data as quickly asyou need them or will you be collecting additionaldata outside of the application process—how willyou manage that if the customer submitted anapplication, but won’t return your phone call? Willyou be using your LOS to submit the HMDA report,or do you need to be testing the integration of yourLOS with your HMDA data aggregation software?Once your software is ready to gather the data,how will you ensure proper documentation of thedata? Technology companies and some of ourinvestors are speculating that the Uniform ResidentialLoan Application (URLA) will not be ready for use until2019 or 2020. So how will you, as the complianceofficer in the back office, accurately document theloan purpose when the current URLA does not ask thequestions needed to solve the loan purpose puzzle?

• Is this a purchase, refi or cash-out refi?

• Does the borrower currently have a dwelling-secured debt?

• Will the loan replace the dwelling secured-debt?

• Will any of the proceeds be used to purchase a
dwelling?

• Will any of the proceeds be used for home-improvement?

Regulations change. Your
momentum doesn’t have to.

The coming data submission and collection changes to
HMDA can be a lot to grasp. We help you keep business in hand.
With our over 30 years of HMDA experience, let us assist you
with the new data rules. As the HMDA rules change, your ability
to rely on us never will.